On behalf of our low-income clients, the National Consumer Law Center submits these comments in response to the U.S. Department of Education’s request for feedback on the proposed application form for the Total and Permanent Disability (TPD) Program. Our comments reflect our experience working directly with low-income borrowers applying for TPD discharge and other federal student loan discharges, as well as feedback from other legal aid attorneys who provide TPD discharge assistance. The recommendations we put forth, if implemented, will make the form more accessible, and less burdensome for disabled borrowers, their representatives, and the medical professionals required to certify a borrower’s disability.
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